Tennessee Code Annotated

Tenn. Code Ann. § 40-35-120 (2026)

Repeat violent offenders - Three strikes

✓ current as of May 2026
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Acts 1994, ch. 994, § 1; 1995, ch. 499, §§ 1-9.


Notes of Decisions
Cited in 74 cases (14 in the last 5 years), 1997–2026 · leading case: State v. Thompson, 36 S.W.3d 102 (Tenn. Crim. App. 2000).
State v. Thompson, 36 S.W.3d 102 (Tenn. Crim. App. 2000). · cites it 61× “A repeat violent offender, see Tenn.Code Ann. § 40-35-120 (1997), the defendant is presently serving a sentence of life without possibility of parole for his crimes.”
State v. Wyrick, 62 S.W.3d 751 (Tenn. Crim. App. 2001). · cites it 30× “See Tenn.Code Ann. § 40-35-120. The defendant contends the following: (1) the presentment is insufficient because it fails to allege his 1987 rape conviction, which is an essential element of the offenses and should be left for the jury’s determination; (2) the evidence is…”
State v. Cooper, 321 S.W.3d 501 (Tenn. 2010). · cites it 27× “We hold that the evidence is sufficient to support the defendant’s conviction and that the trial court did not err in relying on a certified judgment of another state’s court to determine beyond a reasonable doubt that the defendant is a repeat violent offender pursuant to…”
State of Tennessee v. Kevin Patterson AKA John O'Keefe Varner AKA John O'Keefe Kitchen, 538 S.W.3d 431 (Tenn. 2017). · cites it 25× “Tenn. Code Ann. § 40-35-120 (i)(2) (2014 & 2017 Supp.”
State v. Dooley, 29 S.W.3d 542 (Tenn. Crim. App. 2000). · cites it 12× “REPEAT VIOLENT OFFENDER In his final issue, the appellant maintains that the trial court erred in sentencing him as a Repeat Violent Offender to life without parole under Tenn. Code Ann. § 40-35-120 . He argues that Tenn.”
State v. Moretti, 446 P.3d 609 (Wash. 2019). · cites it 2× “§ 17-25-45), Tennessee ( Tenn. Code Ann. § 40-35-120 (g)), Virginia (Va.”
David Cantrell v. Joe Easterling, Warden, 346 S.W.3d 445 (Tenn. 2011). “§ 40-35-120. . We assume for the sake of this discussion that the trial court is applying the correct statutes to its findings of fact when fashioning the sentence.”
Terrance Lavar Davis v. State of Tennessee, 313 S.W.3d 751 (Tenn. 2010). “§ 40-35-120(g). The uniform judgment document designates these sentences by a box labeled “Repeat Violent 100%.”
State of Tennessee v. Kevin Patterson aka John O'Keefe Varner aka John O'Keefe Kitchen (Tenn. Crim. App. 2016). · cites it 53× “” Unlike the deficient pretrial notice in Cooper, the document filed in this case provides that the State “also hereby gives notice to the defendant of its intent to seek to have him declared as a Repeat Violent Offender pursuant to T.C.A. § 40-35-120.” The notice document does…”
State of Tennessee v. Sean Mitchell aka Antwon Rainer (Tenn. Crim. App. 2021). · cites it 23× “Tenn. Code Ann. § 40-35-120 (g) (2020). A trial court cannot abuse its discretion by imposing an excessive sentence where, by statute, the trial court has no discretion.”
State of Tennessee v. Bobby Joe Gentry (Tenn. Crim. App. 2004). · cites it 38× “” Tenn. Code Ann. § 40-35-120 (g). The Defendant then argues that this statute, which mandates that the trial court determine whether the defendant is a violent offender, constitutionally conflicts with Tennessee Code Annotated section 40-35-203(e) (1997),2 which requires that a…”
State of Tennessee v. Mack Mandrell Loyde, AKA Mandrel Loyde, AKA Michael Loyde (Tenn. Crim. App. 2018). · cites it 19× “Tenn. Code Ann. § 40-35-120 (i). In contrast, the State asserts the evidence was sufficient to support the defendant’s three convictions, and that he was properly sentenced as a repeat violent offender pursuant to its timely and sufficient notice of intent to seek enhanced…”
— Tenn. Code Ann. § 40-35-120(a) — 3 cases
State of Tennessee v. Kevin Patterson aka John O'Keefe Varner aka John O'Keefe Kitchen (Tenn. Crim. App. 2016). “” Unlike the deficient pretrial notice in Cooper, the document filed in this case provides that the State “also hereby gives notice to the defendant of its intent to seek to have him declared as a Repeat Violent Offender pursuant to T.C.A. § 40-35-120.” The notice document does…”
State of Tennessee v. Charles Hall (Tenn. Crim. App. 2010).
State of Tennessee v. Frank Lee Tate (Tenn. Crim. App. 2007).
— Tenn. Code Ann. § 40-35-120(a)(1) — 5 cases
State of Tennessee v. Kevin Patterson aka John O'Keefe Varner aka John O'Keefe Kitchen (Tenn. Crim. App. 2016). “” Unlike the deficient pretrial notice in Cooper, the document filed in this case provides that the State “also hereby gives notice to the defendant of its intent to seek to have him declared as a Repeat Violent Offender pursuant to T.C.A. § 40-35-120.” The notice document does…”
State of Tennessee v. David Wayne Eady (Tenn. Crim. App. 2022).
State of Tennessee v. Charles Hall (Tenn. Crim. App. 2010).
— Tenn. Code Ann. § 40-35-120(a)(2) — 2 cases
State of Tennessee v. Kevin Patterson AKA John O'Keefe Varner AKA John O'Keefe Kitchen, 538 S.W.3d 431 (Tenn. 2017). “Tenn. Code Ann. § 40-35-120 (i)(2) (2014 & 2017 Supp.”
State of Tennessee v. Frank Lee Tate (Tenn. Crim. App. 2007).
— Tenn. Code Ann. § 40-35-120(a)(3) — 3 cases
State v. Cooper, 321 S.W.3d 501 (Tenn. 2010). “We hold that the evidence is sufficient to support the defendant’s conviction and that the trial court did not err in relying on a certified judgment of another state’s court to determine beyond a reasonable doubt that the defendant is a repeat violent offender pursuant to…”
State of Tennessee v. Milton Lebron Byrd (Tenn. Crim. App. 2007).
State of Tennessee v. Kevin Patterson aka John O'Keefe Varner aka John O'Keefe Kitchen (Tenn. Crim. App. 2016). “” Unlike the deficient pretrial notice in Cooper, the document filed in this case provides that the State “also hereby gives notice to the defendant of its intent to seek to have him declared as a Repeat Violent Offender pursuant to T.C.A. § 40-35-120.” The notice document does…”
— Tenn. Code Ann. § 40-35-120(a)(5) — 4 cases
State v. Wyrick, 62 S.W.3d 751 (Tenn. Crim. App. 2001). “See Tenn.Code Ann. § 40-35-120. The defendant contends the following: (1) the presentment is insufficient because it fails to allege his 1987 rape conviction, which is an essential element of the offenses and should be left for the jury’s determination; (2) the evidence is…”
State of Tennessee v. George Timmons (Tenn. Crim. App. 2009).
State of Tennessee v. Kevin Patterson aka John O'Keefe Varner aka John O'Keefe Kitchen (Tenn. Crim. App. 2016). “” Unlike the deficient pretrial notice in Cooper, the document filed in this case provides that the State “also hereby gives notice to the defendant of its intent to seek to have him declared as a Repeat Violent Offender pursuant to T.C.A. § 40-35-120.” The notice document does…”
State s. Anthony Lynn Wyrick (Tenn. Crim. App. 2000).
— Tenn. Code Ann. § 40-35-120(a)(6) — 1 case
State of Tennessee v. Sean Mitchell aka Antwon Rainer (Tenn. Crim. App. 2021). “Tenn. Code Ann. § 40-35-120 (g) (2020). A trial court cannot abuse its discretion by imposing an excessive sentence where, by statute, the trial court has no discretion.”
— Tenn. Code Ann. § 40-35-120(b) — 3 cases
— Tenn. Code Ann. § 40-35-120(b)(1) — 1 case
State of Tennessee v. Alvertis Boyd (Tenn. Crim. App. 2011).
— Tenn. Code Ann. § 40-35-120(b)(1)(A) — 1 case
— Tenn. Code Ann. § 40-35-120(b)(1)(B) — 1 case
State of Tennessee v. Kevin Patterson aka John O'Keefe Varner aka John O'Keefe Kitchen (Tenn. Crim. App. 2016). “” Unlike the deficient pretrial notice in Cooper, the document filed in this case provides that the State “also hereby gives notice to the defendant of its intent to seek to have him declared as a Repeat Violent Offender pursuant to T.C.A. § 40-35-120.” The notice document does…”
— Tenn. Code Ann. § 40-35-120(b)(1)(G) — 1 case
— Tenn. Code Ann. § 40-35-120(b)(1)(I) — 1 case
State of Tennessee v. Charles Hall (Tenn. Crim. App. 2010).
— Tenn. Code Ann. § 40-35-120(b)(2) — 1 case
State of Tennessee v. Charles Hall (Tenn. Crim. App. 2010).
— Tenn. Code Ann. § 40-35-120(c)(1)(B) — 1 case
— Tenn. Code Ann. § 40-35-120(d)(1) — 1 case
State of Tennessee v. Sean Mitchell aka Antwon Rainer (Tenn. Crim. App. 2021). “Tenn. Code Ann. § 40-35-120 (g) (2020). A trial court cannot abuse its discretion by imposing an excessive sentence where, by statute, the trial court has no discretion.”
— Tenn. Code Ann. § 40-35-120(d)(1)(E) — 1 case
State v. Wyrick, 62 S.W.3d 751 (Tenn. Crim. App. 2001). “See Tenn.Code Ann. § 40-35-120. The defendant contends the following: (1) the presentment is insufficient because it fails to allege his 1987 rape conviction, which is an essential element of the offenses and should be left for the jury’s determination; (2) the evidence is…”
— Tenn. Code Ann. § 40-35-120(d)(1)(H) — 1 case
State of Tennessee v. Sean Mitchell aka Antwon Rainer (Tenn. Crim. App. 2021). “Tenn. Code Ann. § 40-35-120 (g) (2020). A trial court cannot abuse its discretion by imposing an excessive sentence where, by statute, the trial court has no discretion.”
— Tenn. Code Ann. § 40-35-120(e) — 3 cases
State v. Cooper, 321 S.W.3d 501 (Tenn. 2010). “We hold that the evidence is sufficient to support the defendant’s conviction and that the trial court did not err in relying on a certified judgment of another state’s court to determine beyond a reasonable doubt that the defendant is a repeat violent offender pursuant to…”
State of Tennessee v. Kevin Patterson aka John O'Keefe Varner aka John O'Keefe Kitchen (Tenn. Crim. App. 2016). “” Unlike the deficient pretrial notice in Cooper, the document filed in this case provides that the State “also hereby gives notice to the defendant of its intent to seek to have him declared as a Repeat Violent Offender pursuant to T.C.A. § 40-35-120.” The notice document does…”
— Tenn. Code Ann. § 40-35-120(e)(1) — 1 case
— Tenn. Code Ann. § 40-35-120(e)(1)(A) — 1 case
State of Tennessee v. Mack Mandrell Loyde, AKA Mandrel Loyde, AKA Michael Loyde (Tenn. Crim. App. 2018). “Tenn. Code Ann. § 40-35-120 (i). In contrast, the State asserts the evidence was sufficient to support the defendant’s three convictions, and that he was properly sentenced as a repeat violent offender pursuant to its timely and sufficient notice of intent to seek enhanced…”
— Tenn. Code Ann. § 40-35-120(e)(1)(B) — 1 case
— Tenn. Code Ann. § 40-35-120(e)(2) — 3 cases
State v. Cooper, 321 S.W.3d 501 (Tenn. 2010). “We hold that the evidence is sufficient to support the defendant’s conviction and that the trial court did not err in relying on a certified judgment of another state’s court to determine beyond a reasonable doubt that the defendant is a repeat violent offender pursuant to…”
State of Tennessee v. Kevin Patterson aka John O'Keefe Varner aka John O'Keefe Kitchen (Tenn. Crim. App. 2016). “” Unlike the deficient pretrial notice in Cooper, the document filed in this case provides that the State “also hereby gives notice to the defendant of its intent to seek to have him declared as a Repeat Violent Offender pursuant to T.C.A. § 40-35-120.” The notice document does…”
— Tenn. Code Ann. § 40-35-120(e)(3) — 1 case
State of Tennessee v. Kevin Patterson aka John O'Keefe Varner aka John O'Keefe Kitchen (Tenn. Crim. App. 2016). “” Unlike the deficient pretrial notice in Cooper, the document filed in this case provides that the State “also hereby gives notice to the defendant of its intent to seek to have him declared as a Repeat Violent Offender pursuant to T.C.A. § 40-35-120.” The notice document does…”
— Tenn. Code Ann. § 40-35-120(e)(4) — 2 cases
State v. Cooper, 321 S.W.3d 501 (Tenn. 2010). “We hold that the evidence is sufficient to support the defendant’s conviction and that the trial court did not err in relying on a certified judgment of another state’s court to determine beyond a reasonable doubt that the defendant is a repeat violent offender pursuant to…”
State of Tennessee v. Kevin Patterson aka John O'Keefe Varner aka John O'Keefe Kitchen (Tenn. Crim. App. 2016). “” Unlike the deficient pretrial notice in Cooper, the document filed in this case provides that the State “also hereby gives notice to the defendant of its intent to seek to have him declared as a Repeat Violent Offender pursuant to T.C.A. § 40-35-120.” The notice document does…”
— Tenn. Code Ann. § 40-35-120(e)(l) — 1 case
State v. Wyrick, 62 S.W.3d 751 (Tenn. Crim. App. 2001). “See Tenn.Code Ann. § 40-35-120. The defendant contends the following: (1) the presentment is insufficient because it fails to allege his 1987 rape conviction, which is an essential element of the offenses and should be left for the jury’s determination; (2) the evidence is…”
— Tenn. Code Ann. § 40-35-120(f) — 1 case
State v. Thompson, 36 S.W.3d 102 (Tenn. Crim. App. 2000). “A repeat violent offender, see Tenn.Code Ann. § 40-35-120 (1997), the defendant is presently serving a sentence of life without possibility of parole for his crimes.”
— Tenn. Code Ann. § 40-35-120(f)(2) — 1 case
State v. Cooper, 321 S.W.3d 501 (Tenn. 2010). “We hold that the evidence is sufficient to support the defendant’s conviction and that the trial court did not err in relying on a certified judgment of another state’s court to determine beyond a reasonable doubt that the defendant is a repeat violent offender pursuant to…”
— Tenn. Code Ann. § 40-35-120(g) — 10 cases
State v. Wyrick, 62 S.W.3d 751 (Tenn. Crim. App. 2001). “See Tenn.Code Ann. § 40-35-120. The defendant contends the following: (1) the presentment is insufficient because it fails to allege his 1987 rape conviction, which is an essential element of the offenses and should be left for the jury’s determination; (2) the evidence is…”
State v. Cooper, 321 S.W.3d 501 (Tenn. 2010). “We hold that the evidence is sufficient to support the defendant’s conviction and that the trial court did not err in relying on a certified judgment of another state’s court to determine beyond a reasonable doubt that the defendant is a repeat violent offender pursuant to…”
Terrance Lavar Davis v. State of Tennessee, 313 S.W.3d 751 (Tenn. 2010). “§ 40-35-120(g). The uniform judgment document designates these sentences by a box labeled “Repeat Violent 100%.”
State of Tennessee v. Damien Clark (Tenn. Crim. App. 2015).
— Tenn. Code Ann. § 40-35-120(h) — 2 cases
State of Tennessee v. Frank Lee Tate (Tenn. Crim. App. 2007).
State of Tennessee v. Thomas D. Stanton (Tenn. Crim. App. 2005).
— Tenn. Code Ann. § 40-35-120(i) — 1 case
State v. Thompson, 36 S.W.3d 102 (Tenn. Crim. App. 2000). “A repeat violent offender, see Tenn.Code Ann. § 40-35-120 (1997), the defendant is presently serving a sentence of life without possibility of parole for his crimes.”
— Tenn. Code Ann. § 40-35-120(i)(1) — 4 cases
State v. Thompson, 36 S.W.3d 102 (Tenn. Crim. App. 2000). “A repeat violent offender, see Tenn.Code Ann. § 40-35-120 (1997), the defendant is presently serving a sentence of life without possibility of parole for his crimes.”
State of Tennessee v. Ronald Dotson (Tenn. Crim. App. 2002).
State of Tennessee v. Charles Hall (Tenn. Crim. App. 2006).
— Tenn. Code Ann. § 40-35-120(i)(1997) — 2 cases
State v. Thompson, 36 S.W.3d 102 (Tenn. Crim. App. 2000). “A repeat violent offender, see Tenn.Code Ann. § 40-35-120 (1997), the defendant is presently serving a sentence of life without possibility of parole for his crimes.”
State of Tennessee v. Ronald Dotson (Tenn. Crim. App. 2002).
— Tenn. Code Ann. § 40-35-120(i)(2) — 13 cases
State v. Cooper, 321 S.W.3d 501 (Tenn. 2010). “We hold that the evidence is sufficient to support the defendant’s conviction and that the trial court did not err in relying on a certified judgment of another state’s court to determine beyond a reasonable doubt that the defendant is a repeat violent offender pursuant to…”
State v. Thompson, 36 S.W.3d 102 (Tenn. Crim. App. 2000). “A repeat violent offender, see Tenn.Code Ann. § 40-35-120 (1997), the defendant is presently serving a sentence of life without possibility of parole for his crimes.”
State v. Wyrick, 62 S.W.3d 751 (Tenn. Crim. App. 2001). “See Tenn.Code Ann. § 40-35-120. The defendant contends the following: (1) the presentment is insufficient because it fails to allege his 1987 rape conviction, which is an essential element of the offenses and should be left for the jury’s determination; (2) the evidence is…”
State of Tennessee v. Kevin Patterson AKA John O'Keefe Varner AKA John O'Keefe Kitchen, 538 S.W.3d 431 (Tenn. 2017). “Tenn. Code Ann. § 40-35-120 (i)(2) (2014 & 2017 Supp.”
State of Tennessee v. Kevin Patterson aka John O'Keefe Varner aka John O'Keefe Kitchen (Tenn. Crim. App. 2016). “” Unlike the deficient pretrial notice in Cooper, the document filed in this case provides that the State “also hereby gives notice to the defendant of its intent to seek to have him declared as a Repeat Violent Offender pursuant to T.C.A. § 40-35-120.” The notice document does…”
— Tenn. Code Ann. § 40-35-120(i)(3) — 2 cases
State v. Thompson, 36 S.W.3d 102 (Tenn. Crim. App. 2000). “A repeat violent offender, see Tenn.Code Ann. § 40-35-120 (1997), the defendant is presently serving a sentence of life without possibility of parole for his crimes.”
State of Tennessee v. Charles Hall (Tenn. Crim. App. 2006).
— Tenn. Code Ann. § 40-35-120(i)(l) — 1 case
State v. Dooley, 29 S.W.3d 542 (Tenn. Crim. App. 2000). “REPEAT VIOLENT OFFENDER In his final issue, the appellant maintains that the trial court erred in sentencing him as a Repeat Violent Offender to life without parole under Tenn. Code Ann. § 40-35-120 . He argues that Tenn.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.